The funds apparently come from unpaid royalties on iPad sales for 2011 that France and other EU countries, such as Germany, collect for devices capable of transferring and displaying copyrighted material:

To give a bit of a background, the copie privée is a tax in several countries including France & Germany that is applied to all digital devices that can transfer, read, or otherwise make use of copyrighted material. The tax goes to the SACEM, which then takes the lump sum of all the taxes collected and deals them out to authors, creators, producers, actors, etc. accordingly… the problem here isn’t so much the tax, but that Apple actually charged the consumers this tax, and didn’t pay it out to the SACEM.

“Just to give an example this would make sure that a company cannot declare no revenue in France while having hundreds of staff there and declare a lot of income in the Cayman islands with only one employee.”

Late last month EU Tax Commissioner Algirdas Semeta called for an end to tax havens for large technology multinationals. At the time he claimed ‘loose agreements’ between companies and some EU countries “actually allow aggressive tax planners to shift their profits through EU member states to third countries and to avoid taxation in general.” He has not yet, however, proposed specific legislation to prevent the practice.